G.R. No. 244775 - Yatco vs. Office of the Deputy Ombudsman for Luzon

Petitioner Adelaida Yatco filed a complaint in 2016 with the Office of the Ombudsman against four officials of Biñan, Laguna: Mayor Marlyn B. Alonte-Naguit, Vice Mayor Walfredo R. Dimaguila, Jr., Municipal Accountant Virgilio M. Dimaranan, and Municipal Treasurer Angelita Alonalon.
The complaint charged the respondents with violations of Republic Act Nos. 3019 and 6713, Plunder, Grave Misconduct, Conduct Prejudicial to the Best Interest of the Service, and Dishonesty, specifically related to the purchase of property for municipal cemetery expansion.
Petitioner alleged the transaction was disadvantageous to the government and that Mayor Alonte-Naguit had a financial interest in it.

On August 17, 2017, the Ombudsman issued a Joint Resolution dismissing the complaint for lack of probable cause and insufficient evidence.
Findings included that Alonte-Naguit had no direct or indirect financial interest, as the purchased property excluded the portion owned by her mother, and the purchase price reflected fair market value, negating the charge of gross disadvantage.
The plunder charge failed due to lack of proof of ill-gotten wealth amounting to at least PHP 50 million.
The Ombudsman found no substantial basis for administrative liability, as no laws were violated and no government defrauding occurred.
Petitioner’s motion for reconsideration was denied on April 10, 2018.

Petitioner filed a petition for certiorari under Rule 65 of the Rules of Court before the Court of Appeals (CA), contesting the entire Ombudsman ruling, citing that the Ombudsman consolidated administrative and criminal aspects in its decision.
Respondent Dimaguila moved to dismiss the petition for lack of jurisdiction, which petitioner opposed, asserting based on *Cortes v. Office of the Ombudsman* that in consolidated administrative and criminal cases, the aggrieved party may file either a Rule 43 petition for review with the CA or a Rule 65 certiorari petition with the Supreme Court.

On February 7, 2019, the CA partly dismissed the petition for certiorari, specifically regarding the criminal aspect, ruling it had jurisdiction solely over administrative disciplinary cases from the Ombudsman.
The CA held that the petitioner misconstrued the *Cortes* ruling, which did not recognize alternative remedies covering consolidated cases.
The CA cited jurisprudence, specifically *Duyon v. CA*, which declared the CA exceeded its jurisdiction when reviewing criminal aspects of Ombudsman decisions.

Petitioner appealed the CA’s dismissal of the criminal aspect to the Supreme Court, challenging the ruling that the CA had no jurisdiction over the criminal components of Ombudsman decisions in consolidated cases.

Whether the Court of Appeals correctly dismissed petitioner’s petition for certiorari concerning the criminal aspect of the Ombudsman’s consolidated ruling due to lack of jurisdiction.